Response to the Public Consultation on ‘Building a European Data Economy’

With this submission, we would like to respond, in our personal capacity as researchers, to two issues raised by the European Commission’s public consultation on ‘Building a European Data Economy’, namely: the development of a possible future EU framework for data access (section 1), and the issue of portability in the context of non-personal data (section 2). Regarding both issues, our submission aims to convey two main messages: • A cautious, evidence-based approach should be taken in devising any possible future legislative or non-legislative measures for the European data economy; and • Since a number of legal fields and policy initiatives overlap in this context, there is a strong need to ensure consistency of policies and coherence of law on the European as well as national level.